MiCA Whitepaper












	TABLE OF CONTENTS
	Summary Part A - Information about the offeror or the person seeking admission to trading Part B - Information about the issuer, if different from the offeror or person seeking admission to trading Part C- Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114 Part D - Information about the crypto-asset project Part E - Information about the offer to the public of crypto-assets or their admission to trading Part F - Information about the crypto-assets Part G - Information on the rights and obligations attached to the crypto-assets Part H - information on the underlying technology Part I - Information on risks Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts


	I.01: Date of notification
	18.09.2025


	I.02: Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114
	This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The offeror of the crypto-asset is solely responsible for the content of this crypto-asset white paper.' Where relevant in accordance with Article 6(3), second subparagraph of Regulation (EU) 2023/1114, reference shall be made to 'person seeking admission to trading' or to 'operator of the trading platform' instead of 'offeror'.


	I.03: Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114
	This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto- asset white paper makes no omission likely to affect its import.'


	I.04: Statement in accordance with Article 6(5), points (a), (b), (c) of Regulation (EU) 2023/1114
	The crypto-asset referred to in this white paper may lose its value in part or in full, may not always be transferable and may not be liquid.'


	I.05: Statement in accordance with Article 6(5), point (d) of Regulation (EU) 2023/1114
	TRUE


	I.06: Statement in accordance with Article 6(5), points (e) and (f) of Regulation (EU) 2023/1114
	The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council. The crypto-asset referred to in this white paper is not covered by the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.'

	Summary
	I.07: Warning in accordance with Article 6(7), second subparagraph of Regulation (EU) 2023/1114	Warning This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto – asset on the content of the crypto- asset white paper as a whole and not on the summary alone. The offer to the public of this crypto- asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council (36) or any other offer document pursuant to Union or national law.'
	I.08: Characteristics of the crypto-asset	The $PACK Token is the official utility token for HashPack, the leading retail wallet on Hedera Hashgraph. $PACK Token’s purpose is to incentivize and reward users for using HashPack, and to be used for in-wallet redemptions and services. It does not represent any equity or ownership interest in a legal entity. $PACK tokens are freely transferable, in whole or in part, to third parties, and all associated usage rights and obligations follow the token upon transfer.
	I.09:	$PACK is HashPack Inc’s utility token on the Hedera network. It lets holders earn rewards, reduce fees, vote on product decisions and unlock special in‑wallet features. Total supply is capped at 1 billion tokens. 200 million tokens entered circulation at launch; the rest, unlock gradually over six years on a transparent schedule. No new tokens can be minted. $PACK is live on Hedera‑based decentralised exchanges (e.g., SaucerSwap) and selected centralised exchanges (e.g., GATE, MEXC); more listings may follow.
	I.10: Key information about the offer to the public or admission to trading	HashPack Inc. seeks admission to trading of the $PACK token so as to be compliant with MiCA and in keeping with its mission to make available for trading to its clients a wide range of assets.

	Part A - Information about the offeror or the person seeking admission to trading
	A.1: Name	HashPack Inc.
	A.2: Legal form
	A.3: Registered address
	A.4: Head office
	A.5: Registration Date	24.10.2021
	A.6: Legal entity identifier	2549003ET3669NUD2Q82
	A.7: Another identifier required pursuant to applicable national law	Wyoming filing ID 2021-001046105
	A.8: Contact telephone number	n/a
	A.9: E-mail address	info@hashpack.app
	A.10: Response Time (Days)	HashPack endeavours to reply within fourteen (14) days of receipt.
	A.11: Parent Company
	A.12: Members of the Management body	May Chan; 30 N Gould St, Ste R, Sheridan, Wyoming 82801, USA; President; Jacob d'Razario; 30 N Gould St, Ste R, Sheridan, Wyoming 82801, USA; Secretary; Nicholas Hanna; 30 N Gould St, Ste R, Sheridan, Wyoming 82801; USA; Treasurer; Tyler Cote 30 N Gould St, Ste R, Sheridan, Wyoming 82801, USA; Director;
	A.13: Business Activity	HashPack Inc. provides a non-custodial cryptocurrency wallet and gateway for the Hedera network, enabling users to interact with decentralized applications (dApps), decentralized finance (DeFi), and non-fungible tokens (NFTs). Founded in 2021, it offers a simple, secure user experience across mobile (iOS/Android) and browser (Chrome extension) platforms, with a focus on reducing friction and fostering adoption within the Hedera ecosystem.
	A.14: Parent Company Business Activity
	A.15: Newly Established	TRUE
	A.16: Financial condition for the past three years	HashPack was established in 2021 with the initial capital of USD 2,000,000. HashPack possesses sufficient financial resources generated from the platform fees to cover the costs generated by its business activities. HashPack does not face any financial risks or uncertainties impacting its long-term sustainability.
	A.17: Financial condition since registration	N/A

	Part B - Information about the issuer, if different from the offeror or person seeking admission to trading
	B.1: Issuer different from offeror or person seeking admission to trading	FALSE
	B.2: Name
	B.3: Legal form
	B.4: Registered address
	B.5: Head office
	B.6: Registration Date
	B.7: Legal entity identifier
	B.8: Another identifier required pursuant to applicable national law
	B.9: Parent Company
	B.10: Members of the Management body
	B.11: Business Activity
	B.12: Parent Company Business Activity

	Part C- Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
	C.1: Name
	C.2: Legal form
	C.3: Registered address
	C.4: Head office
	C.5: Registration Date
	C.6: Legal entity identifier of the operator of the trading platform

	C.7: Another identifier required pursuant to applicable national law
	C.8: Parent Company
	C.9: Reason for Crypto-Asset White Paper Preparation
	C.10: Members of the Management body
	C.11: Operator Business Activity
	C.12: Parent Company Business Activity
	C.13: Other persons drawing up the crypto- asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
	C.14: Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

	Part D - Information about the crypto-asset project
	D.1: Crypto-asset project name	PACK Token
	D.2: Crypto-assets name	PACK Token
	D.3: Abbreviation	$PACK
	D.4: Crypto-asset project description	The $PACK Token is the official utility token for HashPack, the leading retail wallet on Hedera Hashgraph. $PACK Token’s purpose is to incentivize and reward users for using HashPack, and to be used for in-wallet redemptions and services.
	D.5: Details of all natural or legal persons involved in the implementation of the crypto-asset project	Issuer/developer: HashPack Inc. 30 N Gould St Ste R Sheridan WY 82801 United States Crypto Asset Service Provider: Payward Global Solutions Limited, (trading as “Kraken”), licensed as a CASP with the CBI (Registration No C559106) C559106 (Ireland), with registered offices at: 70 Sir John Rogerson's Quay Dublin 2 Ireland
	D.6: Utility Token Classification	TRUE
	D.7: Key Features of Goods/Services for Utility Token Projects	$PACK Core At its core, $PACK is a loyalty token designed to reward users for participating in the HashPack platform and connect to our NFT and DeFi ecosystem. Integration of $PACK into HashPack is part of our long term strategy where we aim to add value for our users and make using the wallet fun and engaging. PackBack Rewards (introduction) The first utility of the $PACK Token that will be available on the launch of the token is our PackBack reward system. Users who swap assets in their HashPack wallet will earn $PACK as a reward. Currently, in-wallet swaps have a 1% fee: 0.3% goes to SaucerSwap, and 0.7% goes to HashPack. The PackBack rewards will be a percentage of the 0.7% collected by HashPack and will be sent to the user after the swap is complete. The amount of rewards will fluctuate but will always be a percentage of the fees generated from the wallet. The $HBAR fees are converted to a USD value, and that value is then converted to the equivalent amount in $PACK, which the user receives. This system ensures the longevity of the PackBack program. $PACK Store Purchases The second utility of $PACK is that $PACK can be used for exclusive purchases in the HashPack Store. Since its launch in March 2023, the store has offered various items like NFTs and custom themes to enhance the user experience. The introduction of $PACK to the store expands the range of available products and reinforces its purpose as a loyalty reward token. This allows users to spend their $PACK on items that further improve their wallet experience, creating a key circular utility for the token. We have many ideas for future $PACK exclusive items that will tie into new and existing wallet features. *$PACK Governance The third utility of $PACK is the ability for holders to participate in governance. $PACK holders will be able to vote on a number of initiatives.These initiatives mainly revolve around core product development, as a means to gauge the community’s priority on new features, dApp listings, featured dApps, and other initiatives.
	D.8: Plans for the token	Our Accomplishments We have a track record of innovation on the Hedera network, including: Creating HashConnect, the first secure dApp connection library. Writing the HIP-412 NFT metadata standards. Introducing Secure Trade for trustless peer-to-peer transactions. Building tools and features that have improved the Web3 experience on Hedera. Serving over 95% of the monthly active users in the Hedera ecosystem. Future $PACK Utilities $PACK holders will be able to vote on the direction of the platform. Holding $PACK is a direct signal of engagement, and votes will be proportional to the amount of $PACK held. For example, every 20,000 $PACK in an account is worth one vote. Concierge Collection holders will also receive additional voting power, recognizing their deep commitment to the platform. We are committed to using this governance model to involve our community in the future of HashPack. We are also planning future utilities that will include deeper participation in Decentralized Finance (DeFi) and ecosystem engagement initiatives. $PACK Collaborations We believe in collaboration. We have worked with numerous projects to make $PACK usable across the entire ecosystem, fulfilling our goal of creating a circular economy for the token. Earthlings: Players will be able to use $PACK to send and receive packages in the game. We are also exploring other ways to integrate $PACK to increase engagement. SaucerSwap: We provide $PACK incentives through their LARI rewards program to encourage greater liquidity provision. SENTX Marketplace: We collaborated with SENTX to create a fully integrated NFT marketplace that uses $PACK for transactions. Hashgate & Rooster Salsa: Hashgate integrated HashPack into its e-commerce payment service, allowing Rooster Salsa to accept $PACK payments for their hot sauce. This helps us bridge the gap between Web3 and traditional commerce. Bonzo Finance: We partnered with Bonzo Finance to enable lending and borrowing using $PACK, opening up new DeFi opportunities for users. Hackathons & Themes: We have sponsored hackathons and collaborated with various teams to offer unique, $PACK-exclusive themes to their users.
	D.9: Resource Allocation	N/A
	D.10: Planned Use of Collected Funds or Crypto-Assets	Not applicable - HashPack is seeking admission to trading and does not collect any funds in that context.


	Part E - Information about the offer to the public of crypto-assets or their admission to trading
	E.1: Public Offering or Admission to trading	ATTR
	E.2: Reasons for Public Offer or Admission to trading	Making secondary trading available to the consumers on the Kraken Trading platform in compliance with the MiCA regulatory framework.
	E.3: Fundraising Target	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.4: Minimum Subscription Goals	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.5: Maximum Subscription Goal	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.6: Oversubscription Acceptance
	E.7: Oversubscription Allocation	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.8: Issue Price	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.9: Official currency or any other crypto- assets determining the issue price	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.10: Subscription fee	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.11: Offer Price Determination Method	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.12: Total Number of Offered/Traded Crypto- Assets	Maximum supply is 1,000,000,000 PACK.
	E.13: Targeted Holders	ALL
	E.14: Holder restrictions	No restrictions at network level, although trading platforms may place restrictions in accordance with applicable laws and internal policies. As a result, restrictions may be placed on buyers and sellers of $PACK on the specific platform (most notably KYC-checks). However, such checks or limitations are not imposed by HashPack inc.
	E.15: Reimbursement Notice
	E.16: Refund Mechanism	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.17: Refund Timeline	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.18: Offer Phases	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.19: Early Purchase Discount	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.20: Time-limited offer
	E.21: Subscription period beginning
	E.22: Subscription period end
	E.23: Safeguarding Arrangements for Offered Funds/Crypto-Assets	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.24: Payment Methods for Crypto-Asset Purchase	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.25: Value Transfer Methods for Reimbursement	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.26: Right of Withdrawal	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.27: Transfer of Purchased Crypto-Assets	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.28: Transfer Time Schedule
	E.29: Purchaser's Technical Requirements	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.30: Crypto-asset service provider (CASP) name	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.31: CASP identifier	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	E.32: Placement form	NTAV
	E.33: Trading Platforms name	Payward Global Solutions Ltd t/a Kraken.com
	E.34: Trading Platforms Market Identifier Code (MIC)	PGSL
	E.35: Trading Platforms Access	Kraken.com
	E.36: Involved costs
	E.37: Offer Expenses
	E.38: Conflicts of Interest	We are not aware of any conflicts of interest of the persons involved in the offer to the public or admission to trading, arising in relation to the offer or admission to trading.
	E.39: Applicable law	Any dispute arising out of or in connection with the present white paper white paper shall be governed by and construed and enforced in accordance with the laws of The Netherlands without regard to conflict of law rules or principles, except to the extent that such disputes are governed by applicable law pursuant to the terms and conditions of the respective trading platform on which $PACK has been admitted for trading.
	E.40: Competent court	Any disputes or claims arising out of this white paper will be subject to the exclusive jurisdiction of the courts of The Netherlands.

	Part F - Information about the crypto-assets
	F.1: Crypto-Asset Type	Utility Token
	F.2: Crypto-Asset Functionality	At its core, $PACK is a loyalty token designed to reward users for participating in the HashPack platform and connect to our NFT and DeFi ecosystem. Integration of $PACK into HashPack is part of our long term strategy where we aim to add value for our users and make using the wallet fun and engaging. The first utility of the $PACK Token that will be available on the launch of the token is our PackBack reward system. From day one, users who use the in-wallet swap functionality within HashPack will also receive $PACK as a reward. Part of the objective of $PACK is to make the entry point to Hedera as easy as possible. With the incredibly low fees offered by the network, we aim to make it even more appealing for users to leverage the different services offered inside of the wallet.
	F.3: Planned Application of Functionalities	The functionality described in F.2 is currently live. Further applications are planned to be introduced in the future.
	A description of the characteristics of the crypto-asset, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article
	F.4: Type of white paper	OTHR
	F.5: The type of submission	NEWT
	F.6: Crypto-Asset Characteristics	PACK Token is a crypto-asset to be classified as a utility token and to be used on the HashPack platform.
	F.7: Commercial name or trading name	HashPack
	F.8: Website of the issuer	https://www.hashpack.app/
	F.9: Starting date of offer to the public or admission to trading	22.05.2025
	F.10: Publication date	18.09.2025
	F.11: Any other services provided by the issuer	N/A
	F.12: Identifier of operator of the trading platform	PGSL
	F.13: Language or languages of the white paper	English
	F.14: Digital Token Identifier Code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available	N/A
	F.15: Functionally Fungible Group Digital Token Identifier, where available	N/A

	F.16: Voluntary data flag	FALSE
	F.17: Personal data flag	TRUE
	F.18: LEI eligibility	TRUE
	F.19: Home Member State	The Netherlands
	F.20: Host Member States	Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden

	Part G - Information on the rights and obligations attached to the crypto-assets
	G.1: Purchaser Rights and Obligations	Rights: • Cash‑back on fees: up to 25 % of eligible in‑wallet fees are returned to the purchaser in $PACK. • Earn while you hold: purchasers can stake inside the wallet and earn 5 % per year, withdraw any time. • Governance votes: the purchaser's $PACK balance equals voting power on product features, treasury spending and reward rates. • Exclusive extras: certain themes, collectibles and partner dApps require or discount $PACK. Obligatons: There are no mandatory obligations imposed on $PACK purchasers beyond the general terms of use of the platform.
	G.2: Exercise of Rights and obligations	Cash-back ('PackBack'): the purchaser will receive cash-back in $PACK automatically upon making eligible transactions. Stake: the purchaser can elect to stake within the wallet by selecting the staking option. Votes: votes are given for holding $PACK, proportional to the amount of $PACK held. Prior to voting a snapshot will be taken of accounts to determine their vote counts. Each 20,000 PACK in an account is worth one vote. So a user with 75,000 PACK would have three votes worth of voting power in a specific proposal. Exclusive extras: further instructions on how to obtain these will be provided to users as and when they become available.
	G.3: Conditions for modifications of rights and obligations	The rights and obligations attached to $PACK as described in this white paper reflect information available at the time of issuance. This white paper does not constitute a commitment or guarantee by HashPack or any other party regarding future modifications. The white paper contains no promises, assurances or warranties regarding future token functionality. This section is provided solely for informational purposes.
	G.4: Future Public Offers	No future public offers have been announced at the time of this White Paper.
	G.5: Issuer Retained Crypto-Assets	470,000,000 of crypto will be retained for the purposes of marketing, core development and operations.
	G.6: Utility Token Classification	TRUE
	G.7: Key Features of Goods/Services of Utility Tokens	$PACK is HashPack Inc’s utility token on the Hedera network. It lets holders earn rewards, reduce fees, vote on product decisions and unlock special in‑wallet features.
	G.8: Utility Tokens Redemption	$PACK Core At its core, $PACK is a loyalty token designed to reward users for participating in the HashPack platform and connect to our NFT and DeFi ecosystem. Integration of $PACK into HashPack is part of our long term strategy where we aim to add value for our users and make using the wallet fun and engaging. PackBack Rewards (introduction) The first utility of the $PACK Token that will be available on the launch of the token is our PackBack reward system. Users who swap assets in their HashPack wallet will earn $PACK as a reward. Currently, in-wallet swaps have a 1% fee: 0.3% goes to SaucerSwap, and 0.7% goes to HashPack. The PackBack rewards will be a percentage of the 0.7% collected by HashPack and will be sent to the user after the swap is complete. The amount of rewards will fluctuate but will always be a percentage of the fees generated from the wallet. The $HBAR fees are converted to a USD value, and that value is then converted to the equivalent amount in $PACK, which the user receives. This system ensures the longevity of the PackBack program. $PACK Store Purchases The second utility of $PACK is that $PACK can be used for exclusive purchases in the HashPack Store. Since its launch in March 2023, the store has offered various items like NFTs and custom themes to enhance the user experience. The introduction of $PACK to the store expands the range of available products and reinforces its purpose as a loyalty reward token. This allows users to spend their $PACK on items that further improve their wallet experience, creating a key circular utility for the token. We have many ideas for future $PACK exclusive items that will tie into new and existing wallet features. *$PACK Governance The third utility of $PACK is the ability for holders to participate in governance. $PACK holders will be able to vote on a number of initiatives.These initiatives mainly revolve around core product development, as a means to gauge the community’s priority on new features, dApp listings, featured dApps, and other initiatives.
	G.9: Non-Trading request	TRUE
	G.10: Crypto-Assets purchase or sale modalities	Not applicable. The white paper is published in relation to an admission to trading, not an offer to the public.
	G.11: Crypto-Assets Transfer Restrictions	No restrictions at network level, although trading platforms may place restrictions in accordance with applicable laws and internal policies. As a result, restrictions may be placed on buyers and sellers of $PACK on the specific platform (most notably KYC-checks). However, such checks or limitations are not imposed by HashPack inc.
	G.12: Supply Adjustment Protocols	FALSE
	G.13: Supply Adjustment Mechanisms	None
	G.14: Token Value Protection Schemes	FALSE
	G.15: Token Value Protection Schemes Description	N/A
	G.16: Compensation Schemes	FALSE
	G.17: Compensation Schemes Description	N/A. See answer under Section G.16.
	G.18: Applicable law	Any dispute arising out of or in connection with the present white paper white paper shall be governed by and construed and enforced in accordance with the laws of The Netherlands without regard to conflict of law rules or principles, except to the extent that such disputes are governed by applicable law pursuant to the terms and conditions of the respective trading platform on which $PACK has been admitted for trading
	G.19: Competent court	Any disputes or claims arising out of this white paper will be subject to the exclusive jurisdiction of the courts of The Netherlands.

	Part H - information on the underlying technology
	H.1: Distributed ledger technology	$PACK is implemented on the Hedera Hashgraph public network, which uses a unique consensus mechanism called Hashgraph. Unlike traditional blockchains that use Proof of Work (PoW) or Proof of Stake (PoS) to build a linear chain of blocks, Hashgraph utilizes a Directed Acyclic Graph (DAG) data structure. It achieves consensus through a "gossip about gossip" protocol and virtual voting, which allows for fast transaction speeds, low fees, and high security (specifically, asynchronous Byzantine Fault Tolerance, or aBFT).
	H.2: Protocols and technical standards	$PACK is native to the Hedera network, which relies on the Hashgraph distributed-ledger protocol. Core services are exposed via gRPC and REST APIs, while a JSON-RPC relay provides full EVM compatibility for Solidity smart contracts. Transactions are signed with Ed25519 or ECDSA-secp256k1 keys, and the network’s native Hedera Token Service (HTS) and Smart-Contract Service (EVM) ensure that $PACK integrates smoothly with standard wallets, exchanges and decentralised applications.
	H.3: Technology Used	$PACK uses the native Hedera Token Service (HTS) standard on the Hedera network. A separate “mirror-node” layer streams all consensus data so that anyone can run a read-only node for historical queries without burdening consensus nodes with archival storage.
	H.4: Consensus Mechanism	Hedera Hashgraph employs an asynchronous Byzantine Fault-Tolerant (aBFT) proof-of-stake model. Consensus nodes “gossip” signed events, then use virtual voting, weighted by the amount of $PACK staked to each node, to finalise a total order of transactions. Finality is normally achieved within 3–5 seconds, and compromising consensus would require control of more than one-third of all staked $PACK, providing strong security and high throughput.
	H.5: Incentive Mechanisms and Applicable Fees	Hedera relies on its own incentive model: all transaction fees are paid in the Hedera token (HBAR), and each fee is split into a node fee (to the submitting node), a network fee (shared among all consensus nodes), and a service fee (for the specific Hedera service used). Consensus nodes and their proxy-stakers earn HBAR rewards daily, proportional to the stake and uptime they contribute; rewards are drawn from the Hedera treasury, with no new HBAR minted and no slashing penalties. Thus, users pay predictable HBAR fees when transferring HBAR or invoking Hedera services, while node operators and stakers are compensated in HBAR 30 of 35 for securing and operating the network.
	H.6: Use of Distributed Ledger Technology	FALSE
	H.7: DLT Functionality Description	N/A
	H.8: Audit	TRUE
	H.9: Audit outcome	July 2020; Hedera Platform Audit (FP Complete) The security audit reported: • 0 critical issues (none found) • 0 high issues • 0 medium issues • 4 low issues all subsequently addressed • several informational suggestions; acknowledged and tracked October 2024; “Hedera Blockchain Services ‘Modularization’ Code Review” (NCC Group) The assessment reported: • 0 critical issues (none found) • 0 high issues • 1 medium issue (resolved) • 2 low issues (resolved) • 3 informational notes (acknowledged)

	Part I - Information on risks
	I.1: Offer-Related Risks	The $PACK token's value is highly speculative and has no tangible backing, meaning you could lose your entire investment. Its use in restricted activities could lead to regulatory action and negatively impact its value. The token's tax status is uncertain, so you should seek professional advice, and there is no guarantee it will be exchangeable for future services if the project fails.
	I.2: Issuer-Related Risks	The $PACK project's survival depends on continuous funding as it currently lacks revenue. Mismanaged funds or insufficient capital could jeopardize its goals. The project also faces significant legal risks due to the need to comply with complex international regulations. Failure to do so could result in penalties or operational restrictions. Finally, the project's success is highly dependent on its small core team. The loss of key personnel or an inability to attract talent could severely impact its ability to execute its vision and maintain community trust.
	I.3: Crypto-Assets-related Risks	The $PACK token is highly volatile, with its value swinging wildly due to market sentiment and regulatory news. This can cause sudden losses and affect its liquidity, making it hard to trade. The project also faces technological risks, including smart contract exploits and breaches on exchanges, which could damage the ecosystem. Additionally, if the project fails, the token's utility and value will be diminished. A final risk is asset loss from improper security, such as losing private keys or a custodian failure.
	I.4: Project Implementation-Related Risks	The $PACK project's long-term success is tied to its ability to execute its roadmap. Delays or failures in development could hurt growth and user confidence. The project also relies on external developers and partners; if their progress is slow, or if a partnership fails, the token's adoption could suffer. Finally, the ecosystem faces operational risks like software bugs and cyber-attacks. The project's quick response to these issues is vital to avoid disruptions.
	I.5: Technology-Related Risks	The $PACK token relies on a public blockchain, which poses risks like network congestion, high fees, and potential outages. It is also vulnerable to attacks like a 51% attack and protocol bugs. Future technologies, particularly quantum computing, could threaten its cryptographic security. Furthermore, all transactions are public, which, despite addresses being anonymous, creates privacy concerns as transaction histories can be linked to individuals. This data is subject to scrutiny by regulators and others.
	I.6: Mitigation measures	The project's decentralized governance prevents a single entity from controlling the network, with decisions made by a diverse group of stakeholders. Its codebase is continuously audited to find and fix vulnerabilities. The network's Byzantine Fault Tolerant consensus ensures it remains operational even with malicious participants. To prevent market shocks, a gradual token release schedule reduces sudden price volatility.

	Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
	General information
	S.1: Name	HashPack Inc.
	S.2: Relevant legal entity identifier	2549003ET3669NUD2Q82
	S.3: Name of the crypto- asset	HashPack
	S.4: Consensus Mechanism	Hedera Hashgraph operates on a unique Hashgraph consensus algorithm, a directed acyclic graph (DAG) system that diverges from traditional blockchain technology. It uses Asynchronous Byzantine Fault Tolerance (aBFT) to secure the network.
	S.5: Incentive Mechanisms and Applicable Fees	The $PACK project relies on several key components: 1. Hashgraph Consensus: The network uses an aBFT (asynchronous Byzantine Fault Tolerant) consensus mechanism, ensuring it remains secure and stable even with malicious nodes. 2. Gossip about Gossip: Nodes efficiently share transaction information, allowing each to rapidly learn the full network state. This speeds up communication and minimizes delays. 3. Virtual Voting: Instead of traditional voting messages, nodes reach consensus by simulating votes based on the gossip history. This reduces network congestion and accelerates the consensus process. 4. Deterministic Finality: Once a transaction is confirmed, it is irreversible and final within seconds, which is crucial for applications requiring rapid and certain confirmations. 5. Staking: The project incorporates staking to boost network security. Token holders can stake their tokens to support validator nodes, contributing to the network's resilience.
	S.6: Beginning of the period to which the disclosure relates	2024-05-22
	S.7: End of the period to which the disclosure relates	2024-05-22
	Mandatory key indicator on energy consumption
	S.8: Energy consumption	82133,2125
	Sources and methodologies
	S.9: Energy consumption sources and methodologies	The energy consumption for this asset is calculated using a "bottom-up" approach, where nodes are the central factor. The methodology relies on empirical data from public sources and internal tools, with hardware assumptions based on the requirements for running the client software. We measure the energy consumption of hardware devices in certified labs. To determine the token's energy use, we first calculate the total energy of the Hedera network. A fraction of this is then attributed to the $PACK token based on its network activity. When in doubt, we make conservative, higher estimates for potential environmental impact. Information on hardware and network participants is based on verifiable assumptions, generally assuming economically rational behavior.
	Supplementary key indicators on energy and GHG emissions
	S.10: Renewable energy consumption	N/A
	S.11: Energy intensity	N/A
	S.12: Scope 1 DLT GHG emissions – Controlled	N/A
	S.13: Scope 2 DLT GHG emissions – Purchased	N/A
	S.14: GHG intensity	N/A
	Sources and methodologies
	S.15: Key energy sources and methodologies	N/A
	S.16: Key GHG sources and methodologies	N/A
	Optional indicators

	S.17: Energy mix
	S.18: Energy use reduction
	S.19: Carbon intensity
	S.20: Scope 3 DLT GHG emissions - Value chain
	S.21: GHG emissions reduction targets or commitments
	S.22: Generation of waste electrical and electronic equipment (WEEE)
	S.23: Non-recycled WEEE ratio
	S.24: Generation of hazardous waste
	S.25: Generation of waste (all types)
	S.26: Non-recycled waste ratio (all types)
	S.27: Waste intensity (all types)
	S.28: Waste reduction targets or commitments (all types)
	S.29: Impact of the use of equipment on natural resources
	S.30: Natural resources use reduction targets or commitments
	S.31: Water use
	S.32: Non recycled water ratio

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